Assessing & Regulating Natural Fragrances

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NPA Definition of Natural

The NPA’s “Standard and Certification for Personal Care Products”* allows only those ingredients that “come or are made from a renewable resource found in nature (flora, fauna, mineral), with absolutely no petroleum compounds.” The standard includes an appendix of allowed processes and ingredients. According to the standard, a product seeking the NPA seal must:

be made with at least 95% natural ingredients;

contain only those environmentally friendly and benign synthetic materials allowed under the standard (which contains an appendix detailing allowed materials that must have no suspected health risks as indicated by peer-reviewed third-party scientific literature);

be used only when no viable natural alternative ingredient exists; and

contain ingredients that are U.S. Food and Drug Administration generally recognized as safe (GRAS) and contain no heavy metal residues or other contaminants above acceptable levels detailed in the standard or by the US FDA or Environmental Protection Agency.

Participating companies must be transparent, meaning accurate ingredient disclosure—formulas are not required to be disclosed to defend competitive advantage.

Companies must use the greatest amount of recyclable and postconsumer recycled content in packaging as possible.

No animal testing of ingredients or products is permitted.

Leading up to 2010, when the standard will be reviewed, possibly under a “debate and review” process, to settle differing technical and philosophical points of view. The definition of natural and natural personal care guidelines will thus evolve in time. Eventually, the organization hopes to harmonize with other global natural and organic standards as much as possible to further mitigate consumer and industry confusion. In 2010, the NPA looks to:

disallow all synthetics, except those nature-identical preservatives indicated by the German BDIH and other relevant standards;

require formal INCI nomenclature to describe all cosmetic ingredients; and

By: Jeb Gleason-Allured

Posted: February 27, 2009, from the March 2009 issue of GCI Magazine.

Considering the elasticity of the term in recent years, defining natural can be a complex task, especially in fragrance and personal care. As Daniel Fabricant, vice president of scientific and regulatory affairs at the Natural Products Association (NPA; www.naturalproductsassoc.org) puts it, “With the term ‘natural,’ especially in personal care, it just seems to be free range. Labels are daunting for consumers, but also for some retail people. The most natural thing in [some companies’] products is the picture of the flower on [the label]. If the independent natural products retailers that have been doing this for years were confused, you can be assured that there was confusion at the mass-market level and across other channels.”

Jack Corley, executive vice president of Trilogy Fragrances, works closely with colleagues such as Burt’s Bees’ chief marketing and strategic officer Mike Indursky, and Aubrey Organics’ general manager Curt Valva, in concert with the NPA, and adds, “When we [Trilogy] sit and talk with customers, they say ‘there are too many standards out there.’ They confuse the natural standards all the time with the organic standards. It’s a constant problem. You have to try and educate them—even the bigger companies. They link the two together. We fully support what these committees are doing on the organic side, but there are just too many standards. Of course organic products have to be natural, but not all natural products are organic. What my customer base has been asking me is:

‘I’m going to come out with this skin cream and I don’t know if it’s as natural as I can get it, but I can’t get foaming agents in the organic world, but I know that some of these foaming agents are made from plant materials—they’re natural, but they’re not regulated under USDA NOP. But I still want to do the best I can to introduce a product that’s good for the consumer. Why can’t I just call it natural?’ ”

This sort of complaint spurred Corley and his colleagues to partner with the NPA in the creation and evolution of a natural standard for personal care. “There’s mass confusion in the organic personal care sector,” he says, “with people trying to figure out what they can and can’t do. And you’ve got to imagine, if you’re a product development person working for a large company, your boss is in your office every day showing you another article he read about the explosion in the organic and natural personal care segment and asking: Where are we on this? And the product development person is sitting there saying, ‘I just don’t know what to do.’ ”

Fabricant explains that the beauty industry cannot simply wait around and miss the boat on the naturals boom. “The consumers, in this day and age, want to drive hybrids, they want to get off petroleum dependence ... they want to do something good for the environment and have a low threshold of tolerance for synthetics. People, whether right or wrong, definitely associate something more positive with something that’s natural as opposed to something that isn’t. All of those [factors] combined to form the perfect storm to the point that ‘natural’ has been misused randomly during the past few years in terms of marketing—even on cans of soft drinks.” Meanwhile, the U.S. Food and Drug Administration has not made a serious move to define the term. “Someone needed to do something because of consumer confusion,” says Fabricant.